Eshaan Singal
Direct Tax, Corporate Tax, International Tax & Transfer Pricing | Advisor Litigator Educator Author | Making Tax Make Sense
Contact Info
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I'm Eshaan Singal, founder of Singal Tax Advisors, a specialized tax advisory practice focused on solving complex tax issues with clarity, strategy and defensibility.
My work revolves around helping businesses, founders and professionals navigate taxation beyond routine compliance. Whether it is a scrutiny notice, cross-border transaction, transfer pricing issue or a high-stakes structuring decision, the focus is always on building positions that are practical, sustainable and capable of standing scrutiny.
I don't believe in textbook answers or template solutions. Every position is approached with one fundamental question in mind: can this be properly explained, defended and sustained if challenged?
Areas of work include:
Assessments, notices and appellate litigation
International taxation and DTAA advisory
Transfer pricing planning, benchmarking and documentation
M&A tax structuring and transaction support
Strategic tax advisory for businesses and professionals
Through Singal Tax Advisors, the objective is clear. Not just ensuring compliance, but helping clients take informed tax positions with confidence.
I actively write and speak on taxation, with publications featured on Taxmann, Taxsutra, Chartered Accountant Study Circle Bulletin, Chennai and Ahmedabad Chartered Accountant Journal. The goal has always been simple: cut the noise and focus on what actually works in practice.
If you are dealing with a tax issue, evaluating a transaction or simply want clarity before taking a position, feel free to reach out.
Eshaan Singal
Singal Tax Advisors
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Transfer pricing focus on intangibles and digital transactions demands robust documentation and advanced pricing certainty.
India's transfer pricing framework centers on the arm's length principle, with heightened focus on intangibles, intra-group services, royalties and digital transactions. Tools like Safe Harbor Rules and APAs provide pricing certainty, while evolving benchmarking (including profit-split and multi-year data) and judicial emphasis on contemporaneous documentation and FAR analyses shape dispute outcomes. Increased scrutiny of digital business models and compliance burdens-Master Files, Local Files, and CbCR-raise double taxation risks absent MAPs; best practices include proactive APAs, robust documentation, and early authority engagement. (AI Summary)
Income Tax
Code sharing taxation: DTAA interpretation of chartering and nexus determines tax treatment of shared flight revenues.
The material examines whether revenues from airline code sharing qualify as profits from the operation of aircraft in international traffic under Article 8 of the India-US DTAA, treating code sharing as a form of chartering that can include partial or block space arrangements and emphasizing the necessary functional and economic nexus between such revenues and the carrier's core aviation business. (AI Summary)
Income Tax
Reassessment timelines clarified: pandemic extension upheld while new procedural safeguards must be strictly observed, protecting taxpayer rights.
The Supreme Court held that pandemic period extensions of time apply to assessment years whose statutory deadlines fell within the COVID exclusion period, while requiring strict adherence to the post April 1, 2021 reassessment procedures: issuance of a show cause notice under Section 148A, provision of supporting material, and requisite higher level sanctions under Section 151. The Court further ruled that the period between issuing the SCN and the taxpayer's response is excluded from limitation computation, preserving the residual limitation once the taxpayer replies. (AI Summary)
Income Tax
Fiscally transparent entities treated as residents under DTAA, enabling treaty benefits when taxed via owners.
The article examines whether fiscally transparent entities like US disregarded LLCs qualify as residents under a DTAA by focusing on the meaning of being "liable to tax," the evidentiary role of Tax Residency Certificates, and competing interpretive approaches-including OECD commentary, domestic guidance, and tribunal reasoning-that treat taxation in the hands of owners as satisfying treaty residency requirements. (AI Summary)
Income Tax
DTAA grandfathering upheld; TRC deemed conclusive proof of residence, enabling treaty relief for qualifying cross-border share transfers.
The Delhi High Court held that the Assessee possessed genuine economic substance in Mauritius, that a Tax Residency Certificate should be treated as conclusive proof of residence absent compelling evidence of fraud or sham, and that the DTAA grandfathering provision applied so Limitation of Benefits did not preclude treaty relief for qualifying share acquisitions; domestic anti avoidance rules should not displace treaty entitlement where treaty anti abuse measures and evidence of substance are satisfied. (AI Summary)
Income Tax
Remuneration classification: commission to working partners treated as deductible remuneration, not subject to commission TDS in that context.
Payments labelled as commission to working partners are characterised as part of the composite concept of remuneration for partners and must be tested against partnership remuneration limits and authorisation requirements; TDS on commission or brokerage is to be considered by reference to the payment's characterisation and the exclusion of partner receipts from the salary head. (AI Summary)
Income Tax
General Anti-Avoidance Rule targets transactions lacking commercial substance, denying tax benefits and enabling recharacterisation for tax purposes.
GAAR empowers tax authorities to prioritize substance over form, applying a purpose test and requiring economic substance to sustain tax benefits; where arrangements are primarily aimed at obtaining a tax benefit and lack genuine commercial rationale, authorities may disregard, recharacterize, or reconstruct transactions for tax purposes, subject to evidentiary review, committee scrutiny, and available safe harbors and appeals. (AI Summary)
Income Tax
TaxTMI 
TaxTMI 
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26 Jun 2026 
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